January 24, 2021

Volume XI, Number 24


January 22, 2021

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RMP Rule: What's Going On?

The U.S. Environmental Protection Agency (EPA) adopted revisions to the federal Risk Management Plan (RMP) rule in December 2019, undoing some – but not all – of the program changes adopted in the final days of the Obama administration. Please join Whit Swift and Brittany Pemberton as they review the changes adopted in December and discuss companies’ compliance obligations for their covered processes under those recent changes. As part of that discussion, we will address the legal challenges that have been filed seeking to overturn the recent RMP rule changes and what impact that ongoing uncertainty has on RMP compliance strategies.

© 2020 Bracewell LLPNational Law Review, Volume X, Number 73



About this Author

Whit Swift, Bracewell Law Firm, Environmental Strategies Attorney

Whit advises industrial companies on state and federal air quality permitting and regulations, such as Title V operating permit matters and state and federal new source review permitting. He represents clients in environmental litigation matters and has contested permit matters before the Texas State office of Administrative Hearings.

He has experience assisting major manufacturing, energy, chemical, and petrochemical companies to develop and implement state and federal preconstruction and operating strategies, and provided counsel on compliance...

Brittany M. Pemberton, Attorney, Energy Reg, Bracewell Law Firm

Brittany Pemberton represents clients in energy regulation and policy matters. She focuses on obtaining Federal Energy Regulatory Commission and state authorizations for major projects and transactions as well as federal and state regulatory compliance matters.

While in law school, Brittany worked as a law clerk for the U.S. Senate Committee on the Judiciary’s Subcommittee on Antitrust, Competition Policy and Consumer Rights, the Water Law Office of the U.S. Environmental Protection Agency’s Office of General Counsel, and the Division of Mineral...